State ex rel. Lanter v. Cincinnati

Summary

The First District Court of Appeals of Ohio held that the Cincinnati Citizen Complaint Authority's proceedings were not quasi-judicial because the governing code did not require a hearing or an opportunity to present evidence. The court therefore vacated the common pleas court's administrative-review judgment for lack of subject matter jurisdiction, while affirming dismissal of Sergeant Lanter's mandamus petition because he could not establish a clear legal duty to correct the report.

Holdings

1. The common pleas court lacked subject matter jurisdiction because CCA proceedings are not quasi-judicial proceedings subject to review under section 2506.01.
2. Mandamus was properly dismissed because Lanter failed to establish a clear legal duty requiring the CCA to modify its report.

Questions Presented

1. Whether the common pleas court had subject matter jurisdiction under Ohio Revised Code section 2506.01 to review the CCA's report.
2. Whether the CCA proceedings were quasi-judicial proceedings subject to administrative review.
3. Whether Lanter was entitled to mandamus relief requiring correction of alleged inaccuracies in the CCA report.

Disposition

other